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W.M.D. [proliferation] Sanctions breach and enforcement action


OFAC just issued a violation to MidFirst Bank for transactions it did with an S.D.N. within SIX HOURS of the designation.

The OFAC action is the first enforcement case in OFAC history where:

  • OFAC points to the specific time between when a name went on a list and
  • When the violator was engaged in the transaction.

What exactly happened? Link to action and original sanctions in comments.

  1. MidFirst processed
    1. Five transactions totalling $604,000 on behalf of accounts held by the blocked persons.
    2. Two of those transactions, totalling $400,000, were internal book transfers between one of the blocked person's accounts at MidFirst.
  2. On September 21, 2020,
    1. At 12:36 p.m. EDT,
      • OFAC designated two individuals to the S.D.N. List ("the blocked persons") according to the WMDPSR.
    2. Between 2:00 p.m. EDT and 5:48 p.m. EDT,
      • MidFirst processed five transactions totalling $604,000 on behalf of accounts held by the blocked persons.
    3. Between September 22, 2020, and October 5, 2020,
      • MidFirst processed 29 additional transactions totalling $9,879.02 on behalf of the blocked persons.
    4. Ninety-eight per cent of the post-designation transactions value occurred within six hours of designation.

Who are the S.D.N.s, and why a bank in Oklahoma was doing business with S.D.N.s,

  • Oklahoma has a large energy industry, and
  • The two entities added that day were MAMMUT DIESEL and MAMMUT INDUSTRIAL GROUP P.J.S.



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